Eggshell Audits: Handling Sensitive IRS Examinations, Identifying Criminal Issues, Responding to IRS Summonses

Note: CLE credit is not offered on this program

A live 110-minute CPE webinar with interactive Q&A

This program is included with the Strafford CPE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Monday, January 30, 2023

1:00pm-2:50pm EST, 10:00am-11:50am PST

Early Registration Discount Deadline, Friday, January 6, 2023

or call 1-800-926-7926

This webinar will discuss recognizing and handling sensitive IRS examinations, known colloquially as eggshell audits, for CPAs and tax advisers. Our panel of seasoned tax attorneys will address factors that can turn an IRS exam into a criminal investigation, signs that your client may be targeted for a potential criminal examination, and responding to IRS summonses.


The IRS is boasting a 90.6 percent conviction rate for tax crimes investigated during its most recent fiscal year. This, coupled with the Service's additional hiring of 87,000 agents for audits, means taxpayers and their advisers should be prepared for tax examinations that could progress to criminal investigations. More worrisome than the penalties that result from these examinations is the fact that these convictions usually result in jail time. With taxpayers adding COVID fraud, cybercrimes, and erroneous Employee Retention Credit claims to the list of tax offenses, the number of criminal investigations will continue to increase.

Often a tax adviser may recognize significant, perhaps criminal, issues upfront. If so, should the taxpayer amend a prior year's returns to correct previous errors? Other times a practitioner needs to be able to recognize signs that a civil matter is being considered for criminal prosecution. Client communication is protected under attorney-client privilege, but the same communication may not be protected when it is between a client and a tax preparer. These sensitive audits present unique challenges for tax professionals.

Listen as our panel of former IRS trial attorneys gives practical advice on handling eggshell audits for practitioners representing clients before the IRS.



  1. Overview of federal tax crimes
  2. Factors that can make an IRS audit a sensitive audit
  3. Practical advice on handling an eggshell audit
  4. Responding to IRS summonses and grand jury subpoenas


The panel will cover these and other key issues:

  • Indications that your client may be targeted for a criminal investigation
  • Federal tax crimes that can result in criminal convictions
  • Responding to IRS summonses and grand jury subpoenas
  • Practical advice on handling sensitive or eggshell audits


Drabkin, Igor
Igor S. Drabkin

Holtz, Slavett & Drabkin

Mr. Drabkin represents tax clients in disputes with the IRS and state revenue authorities, both administratively...  |  Read More

Warner, David
David J. Warner

Tax Attorney & Shareholder
Holtz, Slavett & Drabkin

Mr. Warner is a Tax Attorney and the Managing Attorney of the Orange County Office of Holtz, Slavett &...  |  Read More

Attend on January 30

Early Discount (through 01/06/23)

CPE credit processing is available for an additional fee of $39.
CPE processing must be ordered prior to the event. See NASBA details.

Cannot Attend January 30?

Early Discount (through 01/06/23)

CPE credit is not available on downloads.

CPE On-Demand

See NASBA details.